Justia Idaho Supreme Court Opinion Summaries

The State of Idaho sought to build a highway interchange through property owned by Triple Crown Development, LLC. Triple Crown and several related entities, all controlled by Lance Thueson, claimed business damages under Idaho Code section 7-711(2) due to the condemnation. Americrete Land Holding LLC owned land adjacent to the condemned property, and the other intervenor entities conducted business on the Americrete property. Thueson asserted that he intended for River Rock Sand & Gravel LLC to mine gravel on the condemned property, with Thueson Construction, Inc. hauling the material to a concrete plant operated by G&B Redi-Mix on Americrete’s property. However, no mining permits were obtained, and operations never commenced on the condemned property.After the State condemned a portion of Triple Crown’s property and initiated proceedings in the District Court of the Third Judicial District, Canyon County, the parties stipulated to property value and allowed the related entities to intervene. The State moved for summary judgment on the business damages claim, arguing neither Triple Crown nor the intervenors qualified for business damages because Triple Crown did not operate a business on the condemned property and the intervenors' businesses were not located on land owned by Triple Crown. The district court granted summary judgment, dismissing the business damages claims, and denied a motion for reconsideration.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Court held that, under section 7-711(2), only the fee title owner of the condemned property may claim business damages for a business operating on that property or on adjoining land owned by the same owner. Beneficial or joint venture interests are insufficient to qualify as ownership under the statute. The Court also denied the State’s request for attorney fees, finding the appeal was not frivolous or without foundation. View "STATE v. TRIPLE CROWN DEVELOPMENT, LLC" on Justia Law

The case involves a defendant who, while under the influence of alcohol and oxycodone, intentionally crashed his vehicle into a minivan carrying a family of six, causing bodily harm to each member. The State charged the defendant with six counts of aggravated battery, four counts of injury to a child, and one count of misdemeanor driving under the influence. After a mental health evaluation and a period of commitment, the defendant was found fit to proceed and pleaded guilty to all charges.The Third Judicial District Court of Idaho sentenced the defendant to consecutive and concurrent terms for the various counts and orally pronounced that he would receive credit for 477 days of time served. However, the written judgment of conviction ambiguously applied the 477 days of credit to each count, potentially multiplying the credit. The State filed a motion to clarify the sentence, and the district court, at a hearing held without the defendant's presence, clarified its intent that the credit for time served should total 477 days across all counts, not per count. The district court rescinded the original written judgment and issued a superseding judgment of conviction reflecting this intent.The Idaho Court of Appeals affirmed the district court’s amended judgment. The defendant sought review, arguing the district court lacked jurisdiction and authority to issue the amended judgment after the original sentence had been imposed. The Supreme Court of the State of Idaho held that the district court had jurisdiction and authority under Idaho Criminal Rule 35(a) to amend the judgment to resolve the ambiguity between the oral pronouncement and the written judgment. However, the Supreme Court determined that the error was in conducting the resentencing hearing without the defendant’s presence. Accordingly, the Supreme Court vacated the amended judgment and remanded the case for resentencing in the defendant’s presence. View "State v. Mooney" on Justia Law

A certified nurse assistant in Idaho suffered significant injuries, including fractures and tendon tears, after slipping and falling in her employer’s parking lot while working. As a result of her injuries, she underwent three surgeries and experienced ongoing pain and physical limitations, which restricted her from returning to her prior position as a CNA. She was able to continue employment at the same facility in a less physically demanding role as an activities director. Multiple medical and vocational experts concluded that her injuries limited her to light-duty work and that she lost access to a significant portion of the labor market in which she previously participated.After filing a worker’s compensation claim, her case was heard by a referee for the Idaho Industrial Commission. The referee found a 4% permanent physical impairment, a figure not in dispute, but the parties disagreed on her permanent partial disability rating. The claimant sought a 34% rating based on vocational evidence showing a substantial loss in labor market access, while the employer argued for 17%. The Commission ultimately adopted the referee’s recommendation of a 20% rating, discounting the claimant’s evidence as overinflated and expressing skepticism about her future employment limitations, in part because her treating physician did not formally issue medical restrictions.On appeal, the Supreme Court of the State of Idaho set aside the Commission’s order. The Court held that the Commission erred by failing to accept unrefuted evidence supporting the 34% disability rating, by improperly requiring the claimant’s functional capacity assessment to be formally endorsed by her treating physician, and by incorrectly focusing on her retention of her current job rather than her overall access to the labor market. The Court found the record supported the claimant’s proposed 34% rating and concluded that the Commission’s order should be set aside. View "WHITELEY v. LIFE CARE CENTERS OF AMERICA" on Justia Law

A dispute arose among siblings following the death of their sister, who had lived with their father for over a decade. After her passing, one sibling was appointed as the personal representative of her estate and became concerned about the disposition of certain assets, including personal property that may have belonged to the decedent. Another sibling, who had been both trustee of their father's trust and later personal representative of their father’s estate, was alleged to have sold or otherwise disposed of the decedent’s property, including through an auction.The personal representative first sought the return of assets or their value in probate court, but after the respondents denied possessing such assets, the petition was dismissed without prejudice by the magistrate court. Nearly two years later, the personal representative filed a complaint with similar allegations. The magistrate court granted a motion to dismiss, concluding that the claims were barred by the three-year statute of limitations applicable to actions for conversion of personal property. The personal representative appealed to the District Court of the Seventh Judicial District, which affirmed the magistrate court’s dismissal.On further appeal, the Supreme Court of the State of Idaho reviewed whether it had subject matter jurisdiction and whether the lower courts erred in dismissing the complaint as untimely. The Court held that each civil proceeding within a probate matter is independent and a final judgment on any such claim is appealable even if the probate remains open. It also held that the three-year statute of limitations applied to the claims, which were based on the alleged wrongful taking of personal property. The request for attorney fees by the respondent was denied due to lack of supporting argument. The Supreme Court affirmed the district court’s decision. View "BOWEN v. PENROD" on Justia Law

After being arrested for domestic battery against S.O., Nicholas James Orr was subject to a criminal no contact order prohibiting communication with S.O. Despite this order, Orr repeatedly called S.O. from jail and made statements that included urging her to alter her testimony, suggesting she say the incident “didn’t happen,” and implying that her actions could “fix” his legal troubles. The State charged Orr with intimidating a witness under Idaho Code section 18-2604(3), as well as multiple violations of the no contact order.The District Court of the Sixth Judicial District denied Orr’s motion to dismiss the witness intimidation charge. Orr had argued that the statute was facially overbroad under the First Amendment and unconstitutional as applied to his conduct, asserting that the “by any manner” language of the statute criminalized protected speech, including his attempts to persuade S.O. to provide more information or clarify her statements. The district court concluded that the statute did not infringe on protected speech, as it targeted attempts to influence or prevent truthful testimony, and that Orr’s conduct could be interpreted as seeking perjury.Orr entered a conditional guilty plea to the intimidation charge, reserving the right to appeal the denial of his motion to dismiss. The Supreme Court of the State of Idaho reviewed the case de novo and affirmed the district court’s decision. The Idaho Supreme Court held that Idaho Code section 18-2604(3) is not unconstitutionally overbroad because it prohibits speech integral to criminal conduct, such as suborning perjury, which is not protected by the First Amendment. The court also held that, as applied to Orr, the statute was constitutional because his statements could reasonably be interpreted as attempts to convince S.O. to testify untruthfully. The court affirmed the denial of the motion to dismiss. View "State of Idaho v. Orr" on Justia Law

While receiving unemployment benefits, the claimant worked part-time for Terrace Home Health Boise, LLC and reported her earnings to the Idaho Department of Labor. After an audit, the Department determined that she had underreported her earnings in four weekly certifications, resulting in an overpayment of $228. The claimant explained the discrepancies by noting differences in pay periods and her method of calculating wages, as well as possible reporting mistakes due to not recognizing partial hour increments. Terrace Home Health initially reported some errors, but those were subsequently corrected. The Department concluded that the overpayment was not intentional and did not assess penalties, but demanded repayment and advised the claimant of her right to appeal and request a waiver.Following the Department’s determination and subsequent denial of her waiver request, the claimant appealed to the Department’s Appeals Bureau, which held a telephonic hearing. The claimant asserted that the errors were caused by her employer’s reporting and objected to the deduction from her benefit payment. The appeals examiner found that the overpayment resulted from the claimant’s own misreporting and denied her appeal. The claimant further appealed to the Idaho Industrial Commission, reiterating her arguments and raising concerns about the fairness of the hearing. The Commission concluded that the overpayment was due to her error, not Department or employer error, making her ineligible for a waiver, and found no evidence that the hearing was conducted improperly.Upon review, the Supreme Court of the State of Idaho affirmed the Industrial Commission’s decision. The Court held that the claimant forfeited any assignment of error because her appellate briefing failed to comply with Idaho Appellate Rule 35(a)(6), requiring argument and citations to legal authority and the record. As a result, the Commission’s denial of the waiver and affirmation of the repayment obligation was upheld. View "PHELPS v. COMMUNITY HEALTH CLINICS, INC." on Justia Law

Bryan Smith requested court records from the Bonneville County District Court in April 2025, specifically seeking copies of judgments and certificates of service for 169 small claims cases. The Clerk’s Office charged him $352 for the records, relying on a 2017 Administrative Order that set fees for electronic records production. Smith paid the fee after the Clerk refused to reduce the charge, then filed suit against the Clerk in his official capacity, alleging he was overcharged and that Idaho Code section 74-102(10) should control the fee charged for electronic records. He sought declaratory relief and damages for the alleged overcharge.The Seventh Judicial District, Bonneville County, heard cross motions for summary judgment. The Clerk asserted quasi-judicial immunity based on following an administrative court order. The district court granted summary judgment for the Clerk, holding he had absolute quasi-judicial immunity and declining to address the merits of Smith’s claims, including whether the fee was excessive or inconsistent with Idaho law.The Supreme Court of the State of Idaho reviewed the appeal. Applying a de novo standard, the Court held that quasi-judicial immunity is only a defense to personal liability, not official capacity suits, and the district court erred in applying that defense. On the merits, the Court found the 2017 Administrative Order’s fee structure was inconsistent with Idaho Court Administrative Rule 32 and Idaho Code section 74-102(10), which require fees to reflect actual labor and material costs. Smith was overcharged by $330.67. The Supreme Court reversed the district court’s grant of summary judgment, vacated the amended judgment, and remanded with instructions to enter judgment in favor of Smith, directing the Clerk to refund $330.67 and awarding Smith costs on appeal. View "SMITH v. POULTER" on Justia Law

In this case, the plaintiff alleged that he was sexually assaulted by a Catholic priest in 1968, when he was nine years old and attended St. Mary’s Catholic School and Church in Moscow, Idaho, which are part of the Roman Catholic Diocese of Boise. The priest, who died in 1993, allegedly abused the plaintiff while babysitting him at the plaintiff’s home. The plaintiff did not disclose the abuse for over fifty years, first telling his therapist in 2019. In 2021, he filed suit against the Diocese and St. Mary’s, asserting a claim for constructive fraud. He alleged that the Diocese presented priests as trustworthy spiritual authorities while concealing known dangers of pedophilic priests, which he claimed created a power dynamic that enabled the abuse.The case was heard in the District Court of the Second Judicial District of Idaho, Latah County. The Diocese denied the allegations and moved for summary judgment, arguing that the plaintiff could not establish the elements of constructive fraud. The district court granted summary judgment to the Diocese, finding that the plaintiff had not shown a relationship of trust and confidence beyond that of a general parishioner and that a finding to the contrary would require improper inquiry into church doctrine. The district court also held that there was no evidence the Diocese had knowledge of the priest’s alleged misconduct or of pedophilic priests in the Diocese at the relevant time.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Idaho Supreme Court held that the plaintiff failed to establish a relationship of trust and confidence necessary for a constructive fraud claim and that there was no evidence the Diocese made a false representation or omission regarding known dangers. The court found summary judgment appropriate and did not reach constitutional or alternative grounds raised below. View "LERIGET v. THE ROMAN CATHOLIC DIOCESE OF BOISE" on Justia Law

A woman was admitted to a hospital in Twin Falls, Idaho, after displaying confusion and an inability to communicate. Her husband brought her prescribed medication bottles, including Nardil, to the hospital and recalls showing them to various nurses and possibly the attending physician. Despite this, the attending physician prescribed her Paxil, a medication that her psychiatrist had previously discontinued due to its contraindication with Nardil. The woman was administered Paxil while on Nardil and died two days later. Her husband and sons filed a medical malpractice suit against the attending physician and the hospital, alleging that the failure to document and consider her current medication led to her death.The case was first heard in the District Court of the Fifth Judicial District, Twin Falls County. The plaintiffs and defendants engaged in extended discovery, including disputes over timely disclosure of expert witnesses and hospital policies. The district court ultimately excluded the plaintiffs’ key expert testimony, finding it untimely or lacking sufficient foundation, and held that without admissible expert evidence, the plaintiffs could not establish a prima facie case under Idaho’s Medical Malpractice Act. The court granted summary judgment to the defendants and later denied the plaintiffs’ motion for reconsideration. The plaintiffs appealed, but failed to serve their notice of appeal on the defendants, prompting a motion to dismiss the appeal.The Idaho Supreme Court determined that the plaintiffs’ failure to serve the notice of appeal was not a jurisdictional defect requiring dismissal. The court found error in the district court’s decision to strike the plaintiffs’ expert’s declaration, holding that the expert had sufficient foundation to opine on the standard of care. The Supreme Court reversed the summary judgment as to the physician, allowing the case to proceed, but affirmed summary judgment for the hospital regarding nursing staff. The case was remanded for further proceedings, and costs were awarded to the plaintiffs. View "Thaete v. St. Luke's Magic Valley Center" on Justia Law

The parties in this case are the parents of a six-year-old child, who have experienced ongoing conflict since their separation. After initial allegations of domestic violence, the mother was granted temporary sole custody, with the father receiving supervised visitation. Over time, the parties agreed by stipulation to joint legal and physical custody, with the father completing court-ordered intervention programs. Multiple subsequent disputes led to extensive litigation, including motions for contempt, allegations of child abuse, investigations by the Idaho Department of Health and Welfare (IDHW), and the appointment of a parenting time evaluator and a guardian ad litem (GAL). The parent-child relationship was marked by mutual accusations and high conflict, but investigative reports consistently found the child safe and well-cared for in both households.The Magistrate Court of the First Judicial District, Kootenai County, held an eight-day bench trial on a petition to modify custody. The court found a substantial change in circumstances based on the child’s increasing age, impending school enrollment, and escalating parental conflict. It determined that the mother’s allegations of domestic violence and child abuse by the father were unsubstantiated, citing the conclusions of three IDHW investigations, the parenting time evaluator, and the GAL. The court found the mother was the primary instigator of conflict and that the child’s distress was linked to her conduct. The magistrate judge ordered joint legal and physical custody, a week-on, week-off schedule, appointment of a parenting coordinator, supervised exchanges, counseling, and a process for school selection.On appeal, the Supreme Court of the State of Idaho affirmed the magistrate court’s judgment. The main holdings were that substantial and competent evidence supported the findings that no domestic violence or child abuse occurred; the magistrate court did not abuse its discretion in evaluating best-interest factors, delegating limited school-selection authority, or relying on the parenting time evaluation. View "Devai v. Burk" on Justia Law